REHAU POLYMERS PVT.LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 8,, PUNE

In the result, the appeal filed by the assessee is allowed

22 (Pune)], he submitted that\nthe Tribunal in the said decision has held that since the TPO has determined the\nALP at NIL without applying any of the methods, the action of the TPO is not\njustified.\n20. He accordingly submitted that since the TPO has not applied any of the\nprescribed methods for determining the ALP, therefore, in view

QUBIX BUSINESS PARK PRIVATE LIMITED,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-8, PUNE, PUNE

In the result, Ground No.2 of the assessee is allowed for statistical purpose

Bench: DR.DIPAK P. RIPOTE (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

Transfer Pricing Officer under sub- Section (3) of Section 92CA and even under Section 144C(8). The DRP may confirm, reduce or enhance the variations proposed in the draft order and wherefore the word eligible assessee in Clause (1) and (15) and the proposed draft order referred to under Clause 144c(1) and (8) will have to be given full

CAPGEMINI TECHNOLOGY SERVICES INDIA LIMITED ( SUCCESSOR OF ARICENT TECHNOLOGIES HOLDINGS LIMITED),PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX - CIRCLE 1(1), PUNE

In the result, the appeal filed by the assessee is allowed

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita No.2804/Pun/2024 िनधा"रण वष" / Assessment Year: 2021-22 Capgemini Technology V The Assistant Services India Limited[As S Commissioner Of Income Successor In Interest Of Tax-1(1)(1), Pune. Erstwhile Aricent Technologies (Holdings) Limited-Since Amalgamated], Plot No.14, Rajiv Gandhi Infotech Park, Hinjewadi, Phase-Iii, Midc Sez, Village Man, Taluka Mulshi, District- Pune – 411057. Maharashtra. Pan: Aacck8280B Appellant/ Assessee Respondent / Revenue Assessee By Shri Nikhil Pathak – Ar Revenue By Shri Prakash L Pathade –Cit(Dr) Date Of Hearing 19/06/2025 Date Of Pronouncement /06/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Assessment Order Under Section 143(3) R.W.S 144C(13) Of The Income Tax Act, 1961 Dated 29.10.2024 For The A.Y.2021-22, Emanating From The

section 292(b). 6. Now in the instant facts, we observe that the assessee had filed a formal intimation before the DCIT, Transfer Pricing on 11 September 2019 intimating that AIPL has been converted into LLP w.e.f. 21 March 2017 (copy of the same has been placed on record for our perusal). Further, the assessee had also filed letter dated

ARISTON GROUP INDIA PRIVATE LIMITED,PUNE vs. THE ASSESSEMENT UNIT, INCOME TAX DEPARTMENT, NFAC AND THE DCIT, CIRCLE 1(1), PUNE, PUNE

In the result, appeal of the assessee is partly allowed

Bench: Shri R.K.Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1680/Pun/2024 िनधा"रण वष" / Assessment Year: 2020-21 Ariston Group India Private The Assessment Unit, Limited, Income Tax Department, 1St Floor, Office No.103, V National Faceless Mayfai Tower, Wakdewadi, S. Assessment Centre, Shivaji Nagar, Pune-411005. Delhi(“Nfac”), The Dcit, Circle-1(1), Pune. Pan: Aaoca7042D Appellant/ Assessee Respondent / Revenue Assessee By Shri Ketan Ved – Ar Revenue By Shri Prakash L Pathade – Cit(Dr) Date Of Hearing 15/01/2025 Date Of Pronouncement 09/04/2025 आदेश/ Order Per Vinay Bhamore, Jm: This Is An Appeal Filed By The Assessee Against The Assessment Order Passed Under Section 143(3) R.W.S 144C(3) Read With Section 144B Of The Income Tax Act, 1961, Dated 18.06.2024 For A.Y.2020- 21. The Assessee Has Raised The Following Grounds Of Appeal : “Based On The Facts & Circumstances Of The Case, Ariston Group India Private Limited (Hereinafter Referred To As "Ariston India' Or 'The Appellant) Prefers An Appeal For The Assessment Year 2020-21 Against

22,34,455 8 Outstanding Payable as of TNMM/RPM/OM 42,45,09,675 31 March 2020 4.1 The TPO proposed an adjustment only with reference to Management Service Fees. TPO decided Arm’s Length Price of Management Service Fees at Rs.NIL using other method. The DRP has confirmed TPO’s order. ITA No.1680/PUN/2024 [A] 4.2 The basic allegations

DATTATRAY HANMANTRAO DESAI,KARAD vs. PRINCIPAL COMMISSIONER OF INCOME TAX, PUNE

In the result, the appeal filed by the assessee is dismissed

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2018-19

22. We find the provisions of section 263 of the Act read as under: ―263. (1) The [Principal Chief Commissioner or Chief Commissioner or Principal Commissioner] or Commissioner may call for and examine the record of any proceeding under this Act, and if he considers that any order passed therein by the Assessing Officer [or the Transfer Pricing

ASSISTANT COMMISSIONER OF INCOME TAX, KOLHAPUR vs. UNDERCARRIAGE AND TRACTOR PARTS PRIVATE LIMITED, KOLHAPUR

In the result, the appeal of the Revenue is dismissed

Bench: Shri R.K. Panda & Ms. Astha Chandra

22-10-2024 Date of 07-01-2025 Pronouncement : आदेश / ORDER PER ASTHA CHANDRA, JM : The appeal filed by the Revenue is directed against the order dated 23.02.2024 of the Ld. Commissioner of Income Tax (Appeals), Pune-13 [“CIT(A)”] whereby he deleted the penalty of Rs.1,00,53,395/- levied by the Ld. Transfer Pricing Officer, Pune

M/S VODAFONE GLOBAL SERVICES P LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE 1(1),, PUNE

In the result, appeal of the assessee is partly allowed for statistical purposes

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.660/Pun/2022 Assessment Year : 2018-19

Transfer Pricing (TP') Assessment proceedings. 10. The Assessee submits that the variation/reduction of 3 percent to be allowed while determining the arm's length price as envisaged under the proviso to Section 92C(2) of the Act. C. Initiation of penalty proceedings under section 270(A) of the Act. 11. Initiating the penalty proceedings under section

PRECISION CAMSHAFTS LIMITED,PUNE vs. DCIT CIRCLE 1, SOLAPUR

In the result, appeal of the assessee is partly allowed

Bench: Shri Rama Kanta Panda & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2744/Pun/2024 निर्धारण वषा / Assessment Year: 2021-22 Precision Camshafts Limited, V Assessment Unit, E-102/103, Akkalkot Road S Income Tax Department Midc, Solapur – 413006. (National Faceless Maharashtra. Assessment Center), Jurisdiction : Pne C(1), Range 63, Deputy Commissioner Of Income Tax („Dcit‟), Circle-1, Solapur. Pan: Aabcp1086B Appellant/ Assessee Respondent / Revenue Assessee By Shri Nikhil S Pathak - Ar Revenue By Shri Prakash L Pathade – Cit(Dr) Date Of Hearing 21/08/2025 Date Of Pronouncement 12/11/2025 आदेश/ Order Per Vinay Bhamore, Jm: This Is An Appeal Filed By Assessee Against The Assessment Order Under Section 143(3) R.W.S 144C(13) Read With Section 144B Of The Act, 1961 Dated 24.10.2024 For A.Y.2021-22 Emanating From Dispute Resolution Panel‟S Order Passed Under Section 144C(5) Of

transfer pricing study is highly facts based and it differs from case to case and that all the factors in Rule 10B have to be considered for every case and every year independently and that a rate decided in a different case for different set of facts and for different year cannot be adopted as such to the instant Appellant

JADE GLOBAL SOFTWARE PRIVATE LIMITED,PUNE vs. ASSESSMENT UNIT, NATIONAL FACELESS ASSESSMENT CENTRE, PUNE

In the result, the Appeal of the Assessee is allowed for statistical purpose

section 144B of the Income Tax Act, 1961; dated 05.07.2024 for Assessment Year 2020-21. The assessee has raised the following grounds of appeal :\n\"1. Incorrect rejection of TP Study by the Transfer Pricing Officer.\n\n1.1 The TPO erred on facts and in law in rejecting the Transfer Pricing documentation (TP Study) maintained by the Assessee stating that

ZS ASSOCIATES INDIA PVT.LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE -12,, PUNE

In the result, appeal of the assessee is dismissed as withdrawn

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.211/Pun/2022 निर्धारण वषा / Assessment Year: 2017-18 Zs Associates India Private V The Additional / Joint / Limited, S Deputy / Assistant Tower 3, World Trade Centre, Commissioner Of Kharadi, Pune – 411014. Income Tax, Dcit, Circle-12, Pune. Pan:Aaacz2157Q Appellant/ Assessee Respondent /Revenue Assessee By Shri Ninad Patade (Through Virtual) Revenue By Shri Prakash L Pathade Date Of Hearing 11/12/2025 Date Of Pronouncement 06/02/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: In This Case, Assessee Has Filed An Appeal Against The Assessment Order Dated 16.02.2022 Passed U/S.143(3) R.W.S 144C(13) Read With Section 144B Of The Act, 1961 For The A.Y.2017- 18, Emanating From Order Of The Dispute Resolution Panel U/S.144C(5) Of The Act, Dated 06.12.2021, Which In Turn Emanates From Draft Assessment Order U/S.143(3) R.W.S 144C(1) Of The Act

section 1448 of the Income-tax Act, 1961 ("hereinafter referred to as "the Act"] on the following grounds which are independent of and without prejudice to each other General Ground Transfer pricing adjustment of INR 52,79,57,527/- 1.1 On the facts and in circumstances of the case and in law, the learned AO or Transfer Pricing Officer (hereinafter

SPECTRAFORCE TECHNOLOGIES (INDIA) PRIVATE LIMITED,PUNE vs. ACIT, CIRCLE 5, PUNE, PUNE

In the result, appeal of the assessee is partly allowed for statistical purposes as per terms indicated hereinabove

Bench: Dr.Manish Borad & Ms. Astha Chandra

Transfer Pricing Officer. Accordingly, the primary adjustment pertains to the Human Resource and Staff Augmentation Services Segment (SAS). The adjustment in this segment is to be examined only if the adjustment in SAS segment is rejected, leading to reduction in Profit Level Indicator (PLI) of the applicant.” 21. Before us, Ld. Counsel for the assessee has submitted that the above

INCOME TAX OFFICER, WARD - 3(1), PUNE, PUNE vs. SACHIN GOVIND APTE, PUNE

Accordingly, Grounds of appeal raised by the Revenue are dismissed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.1720/Pun/2025 निर्धारण वषा / Assessment Years: 2013-14 The Income Tax Officer, V Sachin Govind Apte, Ward-3(1), Pune. S. 759-63, Prabhat Road, Erandwana, Pune – 411004. Pan: Aavpa9458P Appellant/ Revenue Respondent /Assessee Assessee By Ms.Vaishnavi Badwe Revenue By Shri Amit Bobde - Cit(Dr) Date Of Hearing 16/12/2025 Date Of Pronouncement 03/02/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Revenue Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2013-14 Dated 15.05.2025 Emanating From The Assessment Order Passed Under Section 143(3) Of The Act, Dated 30.03.2016. The Revenue Has Raised The Following Grounds Of Appeal : “1. Whether On The Facts & Circumstances Of The Case & In Law The Hon'Ble Cit (A) Was Justified In Deleting The Addition Of Rs.78,72,000/- Made Under Head Stcg & Disallowance Of Deduction U/S 54F Of The It. Act, 1961? 2. Whether On The Facts & Circumstances Of The Case & In Law The Hon‟Ble Cti (A) Was Justified In Deleting The Addition Of Rs.1,20,00,000/- Made On Account Of Deemed Dividend U/S Section 2(22)(E) Of The I.T. Act, 1961?

transfer, sale, assignment etc. and now the party of the first part has become absolute owner and party of second, third and fourth part agrees not to claim any right, compensation in future and shall confirm the releases of their rights in favour of party of the first part. 3.3 Thus, it is specifically mentioned in the Dissolution Deed that

MEENAMANI GANGA BUILDER LLP ,PUNE vs. PCIT (CENTRAL), PUNE , PUNE

In the result, the appeal of the assessee is dismissed

section\n68 of the Act. Ld. DR further made reference to the following\nwritten submissions :\n“1. Brief facts of the case:\n1.1 The assessee is a firm engaged in the business of real estate. A\nsearch action u/s 132 of the Income Tax Act, 1961 was conducted\non 10.01.2019. Consequently, the assessment was completed u/s\n143(3) r.w.s 153A

RAJKAMAL STONE METAL WORKS,AMBEGAON KHURD, DIST. PUNE vs. ACIT CIRCLE 5 PUNE, PUNE

In the result, the appeal filed by the assessee is allowed

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2017-18

22-10-2024 Date of pronouncement : 25-10-2024 O R D E R PER R.K. PANDA, VP : This appeal filed by the assessee is directed against the order dated 12.02.2024 of the CIT(A) / NFAC, Delhi relating to assessment year 2017-18. 2. Facts of the case in brief, are that the assessee is a firm engaged

DCIT, CIRCLE 8 PUNE, PUNE vs. ALFA LAVAL INDIA PVT LTD, PUNE

In the result, the appeal filed by the Revenue is dismissed

Transfer Pricing Officer (TPO) for\ndetermining the Arm's Length Price (ALP) of the international transactions. The\nTPO vide order dated 28.07.2021 passed u/s 92CA(3) of the Act proposed an\nupward adjustment of Rs.1,78,97,091/- to the international transactions relating to\nthe export of traded spares to the Associated Enterprises (AEs). Subsequently the\nAssessing Officer completed

SATARA ENGINEERING PROJECTS AND EQUIPMENTS PRIVATE LIMITED,SATARA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE, SATARA, SATARA

In the result, the appeal filed by the assessee is allowed

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2450/Pun/2025 Assessment Year : 2024-25

22% u/s.115BAA of the Act. We note that section 115BAB of the Act has a direct bearing on the issue in the instant appeal and the same is reproduced below : “Tax on income of new manufacturing domestic companies. 115BAB. (1) Notwithstanding anything contained in this Act but subject to the provisions of this Chapter, other than those mentioned under section

ACIT, CENTRAL CIRCLE-1, NASHIK, NASHIK vs. RAJENDRA RASIKLAL SHAH, NASHIK

In the result, the appeal of the Revenue is dismissed

Bench: Dr.Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita No.1015/Pun/2024 Assessment Year : 2013-14

22,066/- declared in the return filed for A.Y.2013-14 which was taken up for regular scrutiny and assessment u/s.143(3) of the act completed on 11.01.2016 2 Rajendra Rasiklal Shah assessing the income at Rs.18,64,330/-. Subsequently, based on the information received that the assessee sold an immovable property bearing Survey.No.156/2B, Mouje, Nashik, District Nashik admeasuring

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2), PUNE vs. M/S. BILCARE LIMITED, PUNE

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपीऱ सं. / Ita No.273/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 Dcit, Central Circle-2(2), Vs. M/S. Bilcare Limited, Pune. 601, Icc Trade Tower, Pune- 411016. Pan : Aabcb2242F Appellant Respondent आयकर अपीऱ सं. / Ita No.334/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 M/S. Bilcare Limited, Vs. Dcit, Central Circle- 6Th Floor, B Wing, Icc 2(2), Pune. Trade Tower, Senapati Bapat Road, Pune- 411006. Pan : Aabcb2242F Appellant Respondent

section 259 of the Companies Act of Singapore. The Hon‟ble High Court of Republic Singapore was pleased to grant the permission vide order dated 02.10.2015. Subsequently, the assessee company transferred the shares of 79,33,50,000 ordinary shares of BSPL held by the assessee company for total consideration of Singapore Dollar 1 to Bilcare Packaging Ltd., which